DOCUMENTATION OF E NVIRONMENTAL I NDICATOR DETERMINATION RCRA Corrective Action Environmental Indicator (EI) RCRAInfo Code (CA750) Migration of Contaminated Groundwater Under Control Facility Name: Revlon, Inc., Main Production Facility Facility Address: 55 Talmadge Road, Edison, New Jersey Facility EPA ID#: NJD002520542 Definition of Environmental Indicators (for the RCRA Corrective Action) Environmental indicators (EIs) are measures being used by the Resource Conservation and Recovery Act (RCRA) Corrective Action program to go beyond programmatic activity measures (e.g., reports received and approved) to track changes in the quality of the environment. The two EIs developed to date indicate the quality of the environment in relation to current human exposures to contamination and the migration of contaminated groundwater. An EI for non-human (ecological) receptors is intended to be developed in the future. Definition of “Migration of Contaminated Groundwater Under Control” EI A positive “Migration of Contaminated Groundwater Under Control” EI determination (“YE” status code) indicates that the migration of “contaminated” groundwater has stabilized, and that monitoring will be conducted to confirm that contaminated groundwater remains within the original “area of contaminated groundwater” (for all groundwater “contamination” subject to RCRA corrective action at or from the identified facility (i.e., site-wide)). Relationship of EI to Final Remedies While final remedies remain the long-term objective of the RCRA Corrective Action program, the EIs are near-term objectives which are currently being used as program measures for the Government Performance and Results Act of 1993 (GPRA). The “Migration of Contaminated Groundwater Under Control” EI pertains ONLY to the physical migration (i.e., further spread) of contaminated groundwater and contaminants within groundwater (e.g., non-aqueous phase liquids or NAPLs). Achieving this EI does not substitute for achieving other stabilization or final remedy requirements and expectations associated with sources of contamination and the need to restore, wherever practicable, contaminated groundwater to be suitable for its designated current and future uses. Duration / Applicability of EI Determinations EI determination status codes should remain in the Resource Conservation and Recovery Act Information (RCRAInfo) national database system ONLY as long as they remain true (i.e., RCRAInfo status codes must be changed when the regulatory authorities become aware of contrary information).
Transcript
DOCUMENTATION OF ENVIRONMENTAL INDICATOR DETERMINATION
RCRA Corrective ActionEnvironmental Indicator (EI) RCRAInfo Code (CA750)Migration of Contaminated Groundwater Under Control
Facility Name: Revlon, Inc., Main Production FacilityFacility Address: 55 Talmadge Road, Edison, New JerseyFacility EPA ID#: NJD002520542
Definition of Environmental Indicators (for the RCRA Corrective Action)
Environmental indicators (EIs) are measures being used by the Resource Conservation and Recovery Act(RCRA) Corrective Action program to go beyond programmatic activity measures (e.g., reports receivedand approved) to track changes in the quality of the environment. The two EIs developed to date indicatethe quality of the environment in relation to current human exposures to contamination and the migrationof contaminated groundwater. An EI for non-human (ecological) receptors is intended to be developed inthe future.
Definition of “Migration of Contaminated Groundwater Under Control” EI
A positive “Migration of Contaminated Groundwater Under Control” EI determination (“YE” statuscode) indicates that the migration of “contaminated” groundwater has stabilized, and that monitoring willbe conducted to confirm that contaminated groundwater remains within the original “area ofcontaminated groundwater” (for all groundwater “contamination” subject to RCRA corrective action at orfrom the identified facility (i.e., site-wide)).
Relationship of EI to Final Remedies
While final remedies remain the long-term objective of the RCRA Corrective Action program, the EIs arenear-term objectives which are currently being used as program measures for the GovernmentPerformance and Results Act of 1993 (GPRA). The “Migration of Contaminated Groundwater UnderControl” EI pertains ONLY to the physical migration (i.e., further spread) of contaminated groundwaterand contaminants within groundwater (e.g., non-aqueous phase liquids or NAPLs). Achieving this EIdoes not substitute for achieving other stabilization or final remedy requirements and expectationsassociated with sources of contamination and the need to restore, wherever practicable, contaminatedgroundwater to be suitable for its designated current and future uses.
Duration / Applicability of EI Determinations
EI determination status codes should remain in the Resource Conservation and Recovery Act Information (RCRAInfo) national database system ONLY as long as they remain true (i.e., RCRAInfo status codesmust be changed when the regulatory authorities become aware of contrary information).
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Facility Information
The Revlon, Inc., (Revlon) Main Production Facility is located on a 63.2-acre parcel in Edison Township,Middlesex County, New Jersey. Prior to 1948, the site was used for agricultural purposes. The propertywas purchased by Johnson & Johnson, Inc., in 1948 and was used as a distribution center for its baby careproducts until 1956. Revlon purchased the property and began operations in 1956. Revlon’s primarymanufacturing operations consisted of cosmetic formulations and packaging of lipstick, dusting powder,fragrances, toiletries, nail enamel, and makeup. Raw materials used in manufacturing included naturalmaterials, cosmetic formulations, and a variety of industrial chemicals. In 1985, Revlon entered into amerger agreement with Nicole Acquisition Company. The New Jersey Department of EnvironmentalProtection (NJDEP) viewed this merger as a change of ownership and subjected the property to aninvestigation under the provisions of the New Jersey (NJ) Environmental Cleanup and Responsibility Act(ECRA). In 1992, Revlon ceased operations at the facility. As a result of the ECRA inspection, 23 areasof concern (AOCs) were identified, most of which have been issued no further action (NFA)determinations. AOCs 5 and 6, both of which have subsurface soil contaminated with arsenic, are cappedwith asphalt and included in a deed notice. As a result of past facility operations, groundwater is alsocontaminated at concentrations above the NJ Ground Water Quality Criteria (GWQC). The groundwatercontamination is being remediated through operation of a groundwater extraction and treatment system. On July 25, 1999, a development company, Starwood Heller, LLC (Starwood Heller), purchased theproperty from Revlon. Currently, no manufacturing operations are conducted at this site. However, thefacility is currently leased by several tenants for warehousing and office space. Starwood Heller isconducting remediation activities at the site with oversight from NJDEP and EPA.
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1. Has all available relevant/significant information on known and reasonably suspected releases tothe groundwater media, subject to RCRA Corrective Action (e.g., from Solid Waste ManagementUnits (SWMU), Regulated Units (RU), and Areas of Concern (AOC)), been considered in this EIdetermination?
X If yes - check here and continue with #2 below.
If no - re-evaluate existing data, or
If data are not available, skip to #8 and enter “IN” (more information needed) statuscode.
Summary of AOCs: The AOCs listed below have been identified at the facility and are considered forthis evaluation. A total of 23 AOCs were identified. Of these, all but two (AOCs 5 and 6) have receivedNFA determinations for soil. To facilitate investigation and remediation, areas of groundwatercontamination have been combined into the Groundwater AOC, as outlined in the discussion below. Refer to Attachment 3 of the approved CA725 for Revlon (Ref. 5) for a map of the AOC locations.
AOC 1 Former Crusher, Dumpster, 4,000-Gallon Holding Tank, and Storm Drain Area: This AOC is located east of the hydrocarbon facility building. The holding tank, dumpster, andstorm drain received crusher discharges. Concentrations of beryllium, diethylphthalate, andthallium were detected in the soil at concentrations above the NJ Residential Direct Contact SoilCleanup Criteria (RDCSCC). However, upon the application of the NJDEP ComplianceAveraging procedure, these contaminants in the soil were determined not to be a concern in thisarea. The Compliance Averaging procedure allows for the average contaminant concentration inan AOC to be used to determine compliance with remediation standards or the soil cleanupcriteria, rather than the contaminant concentration of individual samples. The technical rules (atNew Jersey Administrative Code [NJAC] 7:26E-4.9(c)3i) specify certain requirements foraveraging data. NJDEP approved a NFA determination for soil on May 16, 1995. Shallowgroundwater in this area was previously monitored at well MW-21-45, but monitoring was laterdiscontinued due to a consistent lack of detection of groundwater constituents exceeding the NJGWQC. AOC 1 should not be confused with Groundwater AOC 1, which includes AOCs 11, 12,and 13.
AOC 2 Stained Soil Adjacent to the East Side of the Main Manufacturing Building: Initialsoil samples collected at AOC 2 contained volatile organic compounds (VOCs); however, theresults of subsequent sampling events reported VOC concentrations below NJ RDCSCC. NJDEP approved a NFA determination for soil on May 16, 1995. AOC 2 was initially classifiedas a groundwater contamination source location. The primary contaminants of concern werevinyl chloride and trichloroethene, and more recent results (October 2003) also indicate 1,1-dichloroethene concentrations slightly above NJ GWQC. This AOC was determined not to be asource location, and well MW-22-45 was downgraded from a source monitoring well to acompliance monitoring well.
AOC 3 RCRA Drum Storage Pad and Underground Storage Tanks (USTs) 15 and 16: Analysis of initial soil samples from this area revealed thallium at concentrations above NJRDCSCC. Revlon argued that the thallium contamination encountered in soil was naturally
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occurring on a regional scale and not the result of site operations and activities. The NJDEPaccepted the facility’s position and approved a NFA determination for soil on May 16, 1995.
AOC 4 East Stained Paved Area: This AOC is located east of the main manufacturingbuilding. Soil samples collected from this area were tested for metals and VOCs. The resultsshowed that the concentrations of VOCs and metals in the soil did not exceed NJ RDCSCC. NJDEP approved a NFA determination for soil on May 16, 1995.
AOC 5 North Paved Area Adjacent to the Northwest Face of the Main Production Facility: This paved area extends from the centerline of the facility building to the north corner of thebuilding. Soil samples collected from both surface and subsurface soil in this area containedarsenic concentrations. The arsenic concentrations in the soil are attributable to the use ofhistorical fill material. Arsenic concentrations detected in surface soil were below the NJRDCSCC; however, arsenic contamination detected in subsurface soil exceeded the NJ RDCSCC. This area is capped with asphalt, which minimizes the infiltration of water through the arsenic-contaminated soil and prevents human exposure. The soil contamination in this area has beenaddressed by a deed notice.
AOC 6 West Paved Area Adjacent to the Northwest Face of the Main Production Facility: This paved area extends from the centerline of the building to the west corner of the building. Soil samples collected from both surface and subsurface soil in this area contained arsenicconcentrations. The arsenic contamination in the soil is attributable to the use of historical fillmaterial. Arsenic contamination in surface soil was below the NJ RDCSCC; however,concentrations in subsurface soil exceeded the NJ RDCSCC. This area is capped with asphalt,which minimizes the infiltration of water through the arsenic-contaminated soil and also preventshuman exposure. The soil contamination in this area has been addressed by a deed notice.
AOC 7 Holding Pit and Tank: Soil samples were collected from this area, and no constituentswere reported above NJ RDCSCC. NJDEP approved a NFA determination for soil on November17, 1993.
AOC 8 Northern Field Area: Analysis of initial soil samples collected from this area revealedthat thallium was present at concentrations above NJ RDCSCC. Revlon argued that the thalliumcontamination encountered in soil was naturally occurring on a regional scale and not the result ofsite operations and activities. The NJDEP accepted this position and issued a NFA determinationfor soil on May 16, 1995.
AOC 9 Nail Enamel Building Area: Lead and thallium concentrations were detected in soilsamples collected from this area. Revlon argued that the thallium contamination encountered insoil was naturally occurring on a regional scale and not the result of site operations and activities. NJDEP amended the RDCSCC for lead from 100 parts per million (ppm) to 400 ppm, whichremoved lead as a constituent of concern for this area. NJDEP approved a NFA determination forsoil on October 7, 1996.
AOC 10 Raw Material Storage Pad: Analytical results from soil samples collected from thisarea were below NJ RDCSCC. NJDEP approved a NFA determination for soil on November 17,1993.
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AOC 11 Tank Farm 1: This tank farm is located on the west side of the manufacturingbuilding. Soil samples collected from this area revealed that acetone was present above NJRDCSCC; however, the results of subsequent soil sampling indicated that acetone concentrationswere below NJ RDCSCC. NJDEP approved a NFA determination for soil on October 7, 1996. Groundwater samples from monitoring wells adjacent to this AOC (MW-24-45) containedelevated concentrations of acetone (8.01 ppm, April 1999 sampling event). The groundwatercontamination at the site is being remediated through operation of a groundwater extraction andtreatment system, which according to the latest remedial action progress report (February 2004)has decreased acetone concentrations to below the NJ GWQC of 700 µg/L. In accordance withthe NJDEP-approved remedial action work plan (May 16, 1995), this AOC and AOCs 12 and 13are collectively known as Groundwater AOC 1. This should not be confused with the previouslydescribed AOC 1 (former crusher, dumpster, holding tank, and storm drain) for soil.
AOC 12 Holding Pit Located between UST Farms 1 and 2: This AOC is located on thewestern side of the manufacturing building. Soil samples collected around this holding pit areaexhibited concentrations of diethylphthalate above the NJ Impact to Groundwater Soil CleanupCriteria (IGWCC). Based on the analysis of additional soil and water samples, it was determinedthat diethylphthalate did not impact site groundwater. However, the result for total organiccompounds (TOCs) in the subsurface soil was above the NJ Soil Cleanup Criteria for TOCs of10,000 ppm. TOC-impacted soil was excavated, and post-excavation soil samples collected fromthis area indicated that TOCs were below the Soil Cleanup Criteria of 10,000 ppm. NJDEPapproved a NFA determination for soil on October 7, 1996. In accordance with the NJDEP-approved remedial action work plan (May 16, 1995), this AOC and AOCs 11 and 13 arecollectively known as Groundwater AOC 1.
AOC 13 Aboveground Storage Tank (AST) and UST Farm 2: This AOC is located on thewestern side of the manufacturing building. Initial soil samples collected from this area revealedthat acetone was present above NJ RDCSCC; however, subsequent soil sampling indicated thatacetone is present below NJ RDCSCC. NJDEP approved a NFA determination for soil onOctober 7, 1996. This AOC is considered a source location for acetone contamination ingroundwater. The groundwater contamination is being remediated through operation of agroundwater extraction and treatment system. In accordance with the NJDEP-approved remedialaction work plan (May 16, 1995), this AOC and AOCs 11 and 12 are collectively known asGroundwater AOC 1.
AOC 14 Transformer Pad Area: Soil samples collected from this area containedconcentrations of polychlorinated biphenyls (PCBs). Revlon excavated approximately 260 cubicyards of PCB-contaminated soil and collected post-excavation soil samples. After the applicationof NJDEP Compliance Averaging procedure, which allows for the average contaminantconcentration in an area of concern to be used to determine compliance with remediationstandards or the Soil Cleanup Criteria, rather than the contaminant concentration of individualsamples, the concentrations of PCBs in the samples were below NJ RDCSCC. NJDEP approveda NFA determination for soil on July 28, 1994.
AOC 15 Area of the Pump House Building: This area includes a 180-gallon AST for dieselfuel oil storage and two 15,000-gallon USTs for No. 6 fuel oil storage. Analysis of soil samplescollected from these areas identified total petroleum hydrocarbons (TPHs) in the soil. The twoUSTs were excavated and disposed of, and contaminated soil in the area of the 180-gallon AST
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and the pump house building was removed. Analysis of post-excavation soil samples indicatedTPH concentrations in soil below 400 ppm, which is below the NJ Soil Cleanup Criteria for TOCof 10,000 ppm. NJDEP approved a NFA determination for soil on October 7, 1996.
AOC 16 Outflow Area of the Storm Sewer System: Revlon proposed NFA for this area basedupon the observations that the storm sewer system did not contain significant quantities ofsediment and that the integrity of the storm sewer system was intact. NJDEP approved a NFAdetermination for soil on May 16, 1995.
AOC 17 Eastern Field Area: Analysis of soil samples collected from this area revealed concentrations of methylene chloride, thallium, and TPH. Revlon argued that the thalliumcontamination encountered in soil was naturally occurring on a regional scale and not the result ofsite operations and activities. The facility excavated the methylene chloride and TPH-contaminated soil. Analytical results of post-excavation sampling showed that the methylenechloride and TPH concentrations were below NJ RDCSCC and IGWCC. NJDEP approved aNFA determination for soil on October 7, 1996.
AOC 18 Storm Drain, Catch Basin, and Dumpster and Compactor System Area: Soilsamples collected from this area indicated that beryllium was present above NJ RDCSCC. Beryllium concentrations in soil are naturally occurring in this region and arsenic contaminationis not a concern in this area; therefore, NJDEP approved a NFA determination on October 7,1996.
AOC 19 Settling Tank: One sediment and one liquid sample were collected from the settlingtank. The results indicated that TPH and VOC concentrations were below NJ RDCSCC. NJDEPapproved a NFA determination for soil on May 16, 1995.
AOC 20 Proposed Storm Drain Location: Because the storm drain was not constructed,characterization soil sampling of this area was not required. NJDEP approved a NFAdetermination for soil on May 16, 1995.
AOC 21 Storm Drain: This AOC is located in the area of the crusher, dumpster, and the pavedshipping area. One sediment sample was collected from this area and tested for TPH and VOCs. The TPH concentrations were below the NJ Soil Cleanup Criteria for TOC of 10,000 ppm, andthe VOCs concentrations in the sample were below NJ RDCSCC for VOCs of 1 ppm. NJDEPapproved a NFA determination for soil on May 16, 1995.
AOC 22 Hazardous Waste Storage Pad Area: Analysis of soil samples collected from thisarea detected beryllium, cadmium, and lead. After application of NJDEP Compliance Averagingprocedure, which allows for the average contaminant concentration in an area of concern to beused to determine compliance with remediation standards or the Soil Cleanup Criteria, rather thanthe contaminant concentration of individual samples, the concentrations of these contaminants insoil no longer exceeded NJ RDCSCC. Also, analysis of surface soil samples indicated that TPHconcentrations were above the NJ Soil Cleanup Criteria for TOC of 10,000 ppm. Thecontaminated soil was excavated, and analysis of post-excavation soil samples revealed that TPHconcentrations were below the NJ Soil Cleanup Criteria for TOC. NJDEP approved a NFAdetermination for soil on August 8, 1995.
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AOC 23 AST 28 and Concrete Pad: Analysis of soil samples collected from this area revealedthat no constituent concentrations exceeded NJ RDCSCC. NJDEP approved a NFAdetermination for soil on May 16, 1995.
References:
1. Ground Water Remedial Action, Year 2 Annual Progress Report. Prepared by DeMaximis, Inc. Dated January 1998.
2. Quarterly Compliance Monitoring Program Reports. Prepared by DeMaximis, Inc., (Year 3,Quarter 1) May 1998, (Year 3, Quarter 2) July 1998, (Year 3, Quarter 3) August 1998.
3. Remedial Investigation Report, AOCs #5 & #6. Prepared by Environmental Waste ManagementAssociates, LLC. Dated February 1999.
4. Quarterly Groundwater Compliance Monitoring Program Reports. Prepared by EnvironmentalWaste Management Associates, LLC., (Year 4, Quarter 1) March 1999, (Year 4, Quarter 2) April1999, (Year 4, Quarter 3) June 1999.
5. RCRA Corrective Action Environmental Indicator Determination for Revlon, Inc. MainProduction Facility (RCRIS Code CA725, Current Human Exposures Under Control). Preparedby Tetra Tech and EPA. Dated October 16, 2000.
6. Remedial Action Progress Report, Volumes 1 and 2. Prepared by EWMA. Dated February 2004.
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1“Contamination” and “contaminated” describe media containing contaminants (in any form, NAPL or dissolved,vapors, or solids, that are subject to RCRA) in concentrations in excess of appropriate “levels” (appropriate for the protection ofthe groundwater resource and its beneficial uses).
2. Is groundwater known or reasonably suspected to be “contaminated”1 above appropriatelyprotective “levels” (i.e., applicable promulgated standards, as well as other appropriate standards,guidelines, guidance, or criteria) from releases subject to RCRA Corrective Action, anywhere at,or from, the facility?
X If yes - continue after identifying key contaminants, citing appropriate “levels,” andreferencing supporting documentation.
If no - skip to #8 and enter “YE” status code, after citing appropriate “levels,” andreferencing supporting documentation to demonstrate that groundwater is not“contaminated.”
If unknown - skip to #8 and enter “IN” status code.
Rationale:
Groundwater ConditionsThe surface geology at the facility is characterized by overburden that consists of a 7- to 20-foot sequenceof weathered red to red-brown clayey silt with varying amounts of shale fragments and sand (Ref. 1). The overburden is underlain by the Passaic formation. Groundwater underlying the facility occurs inthree water-bearing zones within the Passaic formation. These zones are referred to as the shallow,intermediate, and deep zones. The shallow zone is comprised of weathered to highly weathered redsiltstone that has low hydraulic conductivity and poor hydraulic connection with the underlyingintermediate zone. The intermediate zone consists of red, hard siltstone that is 15 feet thick, but pinchesout to the northwest. The intermediate zone has the highest hydraulic conductivity of the three saturatedzones (Ref. 1). Available documents provide little information on the deep bedrock zone; however, itappears from well designations that wells that penetrate the deep zone extend to a maximum depth of 220feet below ground surface (Ref. 2).
A groundwater extraction and treatment system was implemented on August 9, 1995, to remediategroundwater contamination in the shallow and intermediate zones. Quarterly progress reports have beensubmitted to the NJDEP since system startup. In 1995, the extraction system consisted of one recoverywell (MW-16-120) completed in the intermediate zone. In February 2002, five more monitoring wells(MW-7-40, MW-24-45, MW-16-45, MW-14-42, and MW-13-40) were connected to the recovery systemto pump contaminated groundwater, and an additional recovery well (RW-1-65) was completed in theshallow zone to improve system effectiveness (Ref. 2). Groundwater pumped from the seven wells istreated via solids filtration and air stripping before discharging to the Middlesex County Utility Authoritysanitary sewer system in accordance with applicable permits.
Prior to operation of the groundwater extraction and treatment system, groundwater flow direction wastowards the west and northwest in the shallow and intermediate zones, and north and northwest in thedeep zone (Ref. 2). Water level data collected in 2003 indicate that groundwater in the shallow andintermediate zones generally flows radially inward towards the groundwater extraction and treatmentsystem and that groundwater flow in the deep zone is generally towards the north (Ref. 2).
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Groundwater QualityGroundwater samples are collected from 15 on-site and 3 off-site wells on a quarterly basis (Ref. 2). Refer to Figures 2 and 8-1 of the Remedial Action Progress Report, dated February 2004, for anillustration of monitoring and recovery well locations (Ref. 2).
Groundwater contamination has been documented at the facility on the eastern and western portions ofthe manufacturing building. Table 1 presents the maximum concentrations reported in the shallow andintermediate zones during the most recent quarterly groundwater sampling event (October 2003) (Ref. 2). Only those concentrations that exceed NJ GWQC are included in the summary table. The primaryconstituents of concern are VOCs including acetone, benzene, 1,1-dichloroethene, 1,1-dichloroethane,methylene chloride, trichloroethene, 1,1,1-trichloroethane, trichlorofluoromethane, and vinyl chloride. As indicated in Table 1, contaminant concentrations in the shallow zone are generally one to two ordersof magnitude greater than those reported in the intermediate zone. The deep zone is not currently beingmonitored for water quality. The extraction and treatment system targets the shallow and intermediatezones, since contaminant detections in the deep zone were not significant.
Table 1 - Maximum Contaminant Concentrations Detected in October 2003 (µg/L)
SaturatedZone
Constituent Well I.D. Well Type Concentration NJ GWQC
Vinyl chloride MW-16-120 Recovery 128 5Notes:* = Interim Specific Criteriaµg/L = micrograms per literNJ GWQC = New Jersey Groundwater Quality Criteria or the Practical Quantitation Level (PQL), whichever is higher.
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Maximum contaminant concentrations in the shallow groundwater zone at the facility on the westernportion of the manufacturing building is defined by recovery well RW-1-65 and monitoring wells MW-13-40, MW-14-42, MW-16-45, and MW-24-45 (Table 1) (Ref. 2). Maximum contaminantconcentrations in the intermediate zone occur in recovery well MW-16-120 and monitoring well MW-17-155, which are located a few hundred feet downgradient and to the northwest of the maximumconcentrations in the shallow zone.
Shallow groundwater contamination on the eastern portion of the manufacturing building is reported inmonitoring well MW-22-45, with 1,1-dichloroethene (16.6 µg/L), trichloroethene (485 µg/L), and vinylchloride (10.7 µg/L) concentrations in excess of NJ GWQC (Ref. 2). Contaminant concentrations in thisarea are orders of magnitude lower than concentrations documented on the western portion of themanufacturing building in Table 1.
Impacts to shallow groundwater extend off site as evidenced by detections of 1,1-dichloroethene,trichloroethene, trichlorofluoromethane, and vinyl chloride above NJ GWQC in well MW-29-56. However, the lateral extent of contaminated shallow groundwater on the western portion of themanufacturing building appears to be limited. VOCs were not detected in downgradient well MW-27-50(off site) and were below NJ GWQC in downgradient well MW-18-45 (on site). The intermediate zoneunderlying shallow well MW-29-56 also contains VOC concentrations in excess of NJ GWQC, asreported in intermediate well MW-29-98 (Ref. 2). The downgradient extent in the intermediate zone isdefined by non-detect results for VOCs in downgradient well MW-27-150 (off site) and VOC datacollected in downgradient wells at the Amerchol facility (Ref. 2). Data obtained from Amerchol arediscussed in more detail in the Question 3 response.
References:
1. Remedial Action Workplan Addendum, Revlon Holdings, Inc - Main Production Facility, Edison,New Jersey, Case No. 85804. Prepared by Andrew Swanson and Stephen Fleischacker ofRevlon. Dated August 1994.
2. Remedial Action Progress Report, Volumes 1 and 2. Prepared by EWMA. Dated February 2004.
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2“Existing area of contaminated groundwater” is an area (with horizontal and vertical dimensions) that has beenverifiably demonstrated to contain all relevant groundwater contamination for this determination, and is defined by designated(monitoring) locations proximate to the outer perimeter of “contamination” that can and will be sampled or tested in the futurefor a physical verification that all “contaminated” groundwater remains within this area, and that the further migration of“contaminated” groundwater is not occurring. Reasonable allowances in the proximity of the monitoring locations arepermissible to incorporate formal remedy decisions (i.e., including public participation), allowing a limited area for naturalattenuation.
3. Has the migration of contaminated groundwater stabilized (such that contaminated groundwateris expected to remain within “existing area of contaminated groundwater”2 as defined by themonitoring locations designated at the time of this determination)?
X If yes - continue, after presenting or referencing the physical evidence (e.g.,groundwater sampling/measurement/migration barrier data) and rationale whycontaminated groundwater is expected to remain within the (horizontal orvertical) dimensions of the “existing area of groundwater contamination”2.
If no (contaminated groundwater is observed or expected to migrate beyond thedesignated locations defining the “existing area of groundwater contamination”2)- skip to #8 and enter “NO” status code, after providing an explanation.
If unknown - skip to #8 and enter “IN” status code.
Rationale:
In the Remedial Action Progress Report submitted to NJDEP in February 2004, the facility reports thatthe groundwater extraction and treatment system is maintaining hydraulic control over contaminatedgroundwater at the site (Ref. 3). NJDEP is in agreement that the groundwater extraction system exertshydraulic control both on site and in adjacent off-site areas (Ref. 4). Refer to Figures 8-1 and 8-2 of theRemedial Action Progress Report, dated February 2004, for an illustration of current groundwatercontours in the shallow and intermediate zones, respectively (Ref. 3). In addition to continued operationof the groundwater extraction and treatment system, the facility has proposed expansion of the extractionand treatment system to include wells MW-13-40 and MW-24-45 (Ref. 3). This system refinement,which has received NJDEP approval (Ref. 4), should further enhance the effectiveness of groundwaterremediation and hydraulic control.
As discussed in the response to Question 2, shallow groundwater contamination that extends off site tothe west of the facility (reported in MW-29-56) appears to be limited in lateral extent as evidenced bynon-detect results for VOCs in downgradient well MW-27-50 (off site) and VOC concentrations belowNJ GWQC in downgradient well MW-18-45 (on site). Contaminated groundwater in the intermediatezone underlying shallow off-site well MW-29-56 (reported in MW-29-98) also appears to be limited inlateral extent as evidenced by non-detect results for VOCs in downgradient well MW-27-150 (off site).
Along the northern boundary of the facility, VOC concentrations in intermediate on-site wells MW-15-190 and MW-23-183 exceed NJ GWQC. EPA has expressed concern that groundwater contaminationmay have migrated off site prior to operation of the extraction and treatment system and is now beyondthe capture zone of the extraction system (Ref. 4). Consequently, off-site delineation of contaminantconcentrations may be incomplete (Ref. 1). Environmental Waste Management Associates (EWMA), theowner’s consultant, responded by noting that there are a number of known contaminated sites in the area
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that have the potential to impact existing off-site wells and any future sentinel wells (Ref. 2), whichwould make evaluation of any additional off-site data difficult. The EWMA response indicates that thearea is heavily industrialized and that chlorinated VOC contamination has been documented at several ofthe surrounding facilities. To further address EPA’s concerns regarding off-site contaminant delineation,NJDEP obtained historic (1987 and 1991) groundwater quality results from the Amerchol facility, locatedapproximately 1,000 feet downgradient and northwest of the Revlon facility. The Amerchol facilitymanufactures health care products and is in NJDEP’s Site Remediation Program. The historic resultsindicate that five Amerchol wells reported total VOC concentrations ranging from 6 to 158 µg/L. Referto Figure 2 in the NJDEP letter to Starwood Heller dated July 29, 2004 for a site plan and well locationmap for the Amerchol facility (Ref. 4). Two of these wells (MW-4 and MW-6) also reported VOCdetections in soil, which suggest an independent VOC source on the Amerchol property itself. Non-detected VOC results at two wells (MW-10 and replacement well MW-10A) at the upgradient edge of theAmerchol property (downgradient of Revlon) further suggests that contaminated groundwater from theRevlon facility has not impacted groundwater beneath Amerchol. NJDEP has evaluated these data andconcluded that groundwater contamination from the Revlon facility does not exist in downgradient areasto the northwest. Consequently, no further delineation is required (Ref. 4).
References:
1. Letter to Christopher Richter, Environmental Waste Management Associates (EMWA), fromAlan Staus, USEPA, Re: Former Revlon Main Production Facility, Edison, Middlesex County,NJ, EPA ID#002520542. Dated May 15, 2002.
2. Letter to Alan Straus, USEPA, from Robert DenBleyker, EWMA, Re: Other Chlorinated VOCSites Proximal to Revlon Facility, 55 Talmadge Road, Edison, New Jersey, ISRA Case No’s85804 and 98331, EWMA Case No. 200307. Dated February 13, 2003.
3. Remedial Action Progress Report, Volumes 1 and 2. Prepared by EWMA. Dated February 2004.4. Letter to Scott Heller, Starwood Heller, from Michael Justiniano, NJDEP, Re: Revlon, Inc -
Former Main Production Facility (Revlon), 55 Talmadge Road, Edison Township, MiddlesexCounty, ISRA Case #E85804. Dated July 29, 2004.
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4. Does “contaminated” groundwater discharge into surface water bodies?
If yes - continue after identifying potentially affected surface water bodies.
X If no - skip to #7 (and enter a “YE” status code in #8, if #7 = yes) after providingan explanation and/or referencing documentation supporting that groundwater“contamination”does not enter surface water bodies.
If unknown - skip to #8 and enter “IN” status code.
Rationale:
The nearest major surface water body to the site is the Raritan River, located approximately three miles tothe southwest. As discussed in the responses to Questions 2 and 3, the groundwater extraction system hascreated local groundwater flowpaths towards the extraction wells in the shallow and intermediate zones. Groundwater flow direction outside of the extraction system’s radius of influence is towards the north andnorthwest and away from the Raritan River. The VOC groundwater plume does not discharge todowngradient surface water bodies.
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3As measured in groundwater prior to entry to the groundwater-surface water/sediment interaction (e.g., hyporheic)zone.
5. Is the discharge of “contaminated” groundwater into surface water likely to be “insignificant”(i.e., the maximum concentration3 of each contaminant discharging into surface water is less than10 times their appropriate groundwater “level,” and there are no other conditions (e.g., the nature,and number, of discharging contaminants, or environmental setting), which significantly increasethe potential for unacceptable impacts to surface water, sediments, or ecosystems at theseconcentrations)?
If yes - skip to #7 (and enter “YE” status code in #8 if #7 = yes), afterdocumenting: 1) the maximum known or reasonably suspected concentration3 ofkey contaminants discharged above their groundwater “level,” the value of theappropriate “level(s),” and if there is evidence that the concentrations areincreasing; and 2) provide a statement of professional judgement/explanation (orreference documentation) supporting that the discharge of groundwatercontaminants into the surface water is not anticipated to have unacceptableimpacts to the receiving surface water, sediments, or ecosystem.
If no - (the discharge of “contaminated” groundwater into surface water ispotentially significant) - continue after documenting: 1) the maximum known orreasonably suspected concentration3 of each contaminant discharged above itsgroundwater “level,” the value of the appropriate “level(s),” and if there isevidence that the concentrations are increasing; and 2) for any contaminantsdischarging into surface water in concentrations3 greater than 100 times theirappropriate groundwater “levels,” the estimated total amount (mass in kg/yr) ofeach of these contaminants that are being discharged (loaded) into the surfacewater body (at the time of the determination), and identify if there is evidencethat the amount of discharging contaminants is increasing.
If unknown - enter “IN” status code in #8.
Rationale:
Not applicable. See the response to Question 4.
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4Note, because areas of inflowing groundwater can be critical habitats (e.g., nurseries or thermal refugia) for manyspecies, an appropriate specialist (e.g., ecologist) should be included in management decisions that could eliminate these areas bysignificantly altering or reversing groundwater flow pathways near surface water bodies.
5The study of the impacts of contaminated groundwater discharges into surface water bodies is a rapidly developingfield, and reviewers are encouraged to look to the latest guidance for the appropriate methods and scale of demonstration to bereasonably certain that discharges are not causing currently unacceptable impacts to the surface water, sediment, or eco-systems.
6. Can the discharge of “contaminated” groundwater into surface water be shown to be “currentlyacceptable” (i.e., not cause impacts to surface water, sediments or ecosystems that should not beallowed to continue until a final remedy decision can be made and implemented4)?
If yes - continue after either: 1) identifying the Final Remedy decisionincorporating these conditions, or other site-specific criteria (developed for theprotection of the site’s surface water, sediments, and ecosystems), andreferencing supporting documentation demonstrating that these criteria are notexceeded by the discharging groundwater; OR 2) providing or referencing aninterim-assessment5, appropriate to the potential for impact, that shows thedischarge of groundwater contaminants into the surface water is (in the opinionof a trained specialist, including an ecologist) adequately protective of receivingsurface water, sediments, and ecosystems, until such time when a full assessmentand final remedy decision can be made. Factors which should be considered inthe interim-assessment (where appropriate to help identify the impact associatedwith discharging groundwater) include: surface water body size, flow,use/classification/habitats and contaminant loading limits, other sources ofsurface water/sediment contamination, surface water and sediment sample resultsand comparisons to available and appropriate surface water and sediment“levels,” as well as any other factors, such as effects on ecological receptors (e.g.,via bio-assays/benthic surveys or site-specific ecological Risk Assessments), thatthe overseeing regulatory agency would deem appropriate for making the EIdetermination.
If no - (the discharge of “contaminated” groundwater can not be shown to be“currently acceptable”) - skip to #8 and enter “NO” status code, afterdocumenting the currently unacceptable impacts to the surface water body,sediments, and/or ecosystem.
If unknown - skip to 8 and enter “IN” status code.
Rationale:
Not applicable. See the response to Question 4.
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7. Will groundwater monitoring / measurement data (and surface water/sediment/ecological data, asnecessary) be collected in the future to verify that contaminated groundwater has remained withinthe horizontal (or vertical, as necessary) dimensions of the “existing area of contaminatedgroundwater?”
X If yes - continue after providing or citing documentation for planned activities or
future sampling/measurement events. Specifically identify the well/measurementlocations which will be tested in the future to verify the expectation (identified in#3) that groundwater contamination will not be migrating horizontally (orvertically, as necessary) beyond the “existing area of groundwatercontamination.”
If no - enter “NO” status code in #8.
If unknown - enter “IN” status code in #8.
Rationale:
Groundwater quality and flow direction have been monitored at on-site and off-site locations since thegroundwater extraction and treatment system was implemented on August 9, 1995. The monitoringprogram consists of quarterly groundwater sampling at 15 on-site and 3 off-site wells (Ref. 1). The on-site wells consist of nine shallow and six intermediate wells, and the off-site wells consist of one shallowand two intermediate wells. Two on-site shallow wells (MW-15-40 and MW-18-45), an off-site shallowwell (MW-27-50), and an off-site intermediate well (MW-27-150) were removed from the quarterlygroundwater quality monitoring program due to lack of significant contamination. All groundwatersamples are analyzed for VOCs (VO+10) including acetone and ethanol. Wells currently included in thegroundwater monitoring program are listed in Table 2 below.
Table 2 - Wells Currently Included in the Quarterly Groundwater Quality Monitoring Program
Groundwater levels also continue to be measured at existing on and off site shallow, intermediate, anddeep wells. According to the latest Remedial Action Progress Report, the monitoring program is ongoingand will continue on a quarterly basis (Ref. 1).
References:
1. Remedial Action Progress Report, Volumes 1 and 2. Prepared by EWMA. Dated February 2004.
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8. Check the appropriate RCRIS status codes for the Migration of Contaminated GroundwaterUnder Control EI (event code CA750), and obtain Supervisor (or appropriate Manager) signatureand date on the EI determination below (attach appropriate supporting documentation as well as amap of the facility).
X YE - Yes, “Migration of Contaminated Groundwater Under Control” has beenverified. Based on a review of the information contained in this EIdetermination, it has been determined that the “Migration of ContaminatedGroundwater” is “Under Control” at the Revlon Inc. Main Production Facility,EPA ID# NJD002520542, located at 55 Talmadge Road, Edison, New Jersey. Specifically, this determination indicates that the migration of “contaminated”groundwater is under control, and that monitoring will be conducted to confirmthat contaminated groundwater remains within the “existing area of contaminatedgroundwater.” This determination will be re-evaluated when the Agencybecomes aware of significant changes at the facility.
NO - Unacceptable migration of contaminated groundwater is observed orexpected.
IN - More information is needed to make a determination.
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Completed by: _____________________________ Date:___________________Lucas KingstonHydrogeologistBooz Allen Hamilton
Reviewed by: _____________________________ Date:___________________Michele BenchoukEnvironmental ConsultantBooz Allen Hamilton
_____________________________ Date:___________________Alan Straus, Project ManagerRCRA Programs BranchEPA Region 2
_____________________________ Date:___________________Barry Tornick, Section ChiefRCRA Programs BranchEPA Region 2
Approved by: Original sigbed by: Date: 9/30/2004Adolph Everett, ChiefRCRA Programs BranchEPA Region 2
Locations where references may be found:
References reviewed to prepare this EI determination are identified after each response. Referencematerials are available at the USEPA Region 2, RCRA Records Center, located at 290 Broadway, NewYork, New York.
Contact telephone and e-mail numbers: Mr. Alan StrausU.S. Environmental Protection Agency - Region 2290 BroadwayNew York, NY 10007-1866Ph: (212) 637-4167E-mail: [email protected]
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Attachments
The following attachment has been provided to support this EI determination.
< Attachment 1 Summary of Media Impacts Table
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Attachment 1 Summary of Media Impacts Table
Revlon, Inc., Main Production Facility
AREA OF CONCERN GWAIR
(Indoors)SURFSOIL
SURFWATER SED
SUB SURFSOIL
AIR(Outdoors)
CORRECTIVEACTION MEASURE
KEYCONTAMINANTS
AOC 1: Crusher, dumpster,holding tank, and storm drainarea
No No No No No No No NA VOCs
AOC 2: Stained soil on eastside of Manufacturing Bldg.
Yes No No No No No No GW Monitoring VOCs
AOC 3: RCRA drum storagepad and USTs 15 & 16
No No No No No No No NA NA
AOC 4: Stained paved areaeast of Manufacturing Bldg.
No No No No No No No NA NA
AOC 5: North paved areaadjacent to northwest face ofBldg. From centerline to northcorner
No No Yes No No Yes No Addressed by DeedNotice
Arsenic
AOC 6: West paved areaadjacent to northwest face ofBldg. From centerline to westcorner
No No Yes No No Yes No Addressed by DeedNotice
Arsenic
AOC 7: Holding pit and tank No No No No No No No NA NA
AOC 8: Northern field area No No No No No No No NA NA
AOC 9: Nail enamel buildingarea
No No No No No No No NA NA
AOC 10: Raw material storagepad
No No No No No No No NA NA
AOC 11: Tank farm 1 Yes No No No No No No GW Extraction andTreatment System
VOCs
AOC 12: Holding pit betweenUSTs 1 & 2
No No No No No Yes No Excavated ContaminatedSoil
TOC
AOC 13: Tank farm 2 Yes No No No No No No GW Extraction andTreatment System
VOCs
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Attachment 1 Summary of Media Impacts Table
Revlon, Inc., Main Production Facility
AREA OF CONCERN GWAIR
(Indoors)SURFSOIL
SURFWATER SED
SUB SURFSOIL
AIR(Outdoors)
CORRECTIVEACTION MEASURE
KEYCONTAMINANTS
AOC 14: Transformer padarea
No No No No No No No Excavated ContaminatedSoil
PCBs
AOC 15: Area of the pumphouse bldg.
No No No No No No No Excavated ContaminatedSoil
TPH
AOC 16: Outflow area fromstorm sewer
No No No No No No No NA NA
AOC 17: Eastern field area No No No No No No No Excavated ContaminatedSoil
Methylene chlorideand TPHs
AOC 18: Storm drain, catchbasin, and dumpster andcompactor system area
No No No No No No No NA NA
AOC 19: Settling tank No No No No No No No NA NA
AOC 20: Proposed storm drainlocation
No No No No No No No NA NA
AOC 21: Storm drain locatedin the area of crusher/dumpsterand paved shipping area
No No No No No No No NA NA
AOC 22: Hazardous wastestorage pad area
No No No No No No No Excavated ContaminatedSoil
TPH
AOC 23: AST 28 and concretepad
No No No No No No No NA NA
Notes:PCB = Polychlorinated biphenylTCE = TrichloroetheneTOC = Total Organic CarbonTPH = Total petroleum hydrocarbons
